The Future of Manifest Disregard As a Valid Ground for Vacating Arbitration Awards in Light of Supreme Court’s Ruling in Hall Street Associates, L.L.C. v. Mattel, Inc.
By Ann C. Gronlund, February 8, 2012
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This note discusses the implications of the Supreme Court decision Halt Street Associations, L.L.C. v. Mattel, Inc. for the common-law doctrine of manifest disregard of the law. After analyzing the circuit split that has developed on this issue, the note argues that the Supreme Court would most likely hold that manifest disregard is no longer a valid ground for a vacatur of arbitral awards under the Federal Arbitration Act.
